ICRYPEX BİLİŞİM A.Ş. ANTI-MONEY LAUNDERING (AML) POLICY

Money laundering is the cover-up of illegal sources by converting them into cash or apparently legitimate investments.

As Icrypex, we take the issue of providing the best customer service seriously, including giving great importance to our customers and account security. In any case, we strictly adhere to AML (Know Your Customer) policy to prevent money laundering. In this context, Money Laundering Policy (hereinafter referred to as "AML Policy") outlines procedures and mechanisms set by Icrypex to prevent money laundering.

The purpose of the Anti-Money Laundering Policy is; to evaluate customers, transactions and services within Icrypex Teknoloji Anonim Şirketi and to decrease the risk with the risk-based approach, to raise awareness and inform employees about laundering of crime revenues and the prevention of terrorism financing and to inform the customers that the Company performs its business in accordance with the applicable legislation, especially the Law on the Prevention of Laundering of Crime Revenues No. 5549 and the Law on Prevention of Terrorism Financing No. 6415.

Within the scope of this AML Policy, customers for whom AML policy is applied in order not to prejudice the Company's activities refer to the real person who is a member of the platform ("Platform") accessed from www.icrypex.com and who benefits from services provided on the Platform and who accepts the matters in this AML Policy in return.

Icrypex has regulated AML Policy in accordance with international law norms and standards, applicable legislation and for the application of this policy; it has taken many measures such as verifying the identity of all customers to a reasonable level, applying a risk-based approach to follow customer-related transactions, notifying the relevant institutions and organizations of any suspicious transaction by customers within the framework of the legislation and recording the transactions, implementing AML Policy at the Company and providing the necessary organization to coordinate its applicability.

Accordingly, Icrypex Follows The Following Policies:

Not engaging in business relationships with criminals and/or terrorists;

Not facilitating any action related to crime and/or terrorist activities;

Risk Assessment

Icrypex adopts a risk-based approach for money laundering and terrorism financing in accordance with both national and international requirements. Therefore, measures to prevent money laundering and finance terrorism are proportional to the risks identified and allow an effective dedication of resources. Resources are used on a priority basis and the greatest attention is given to the greatest risks.

Icrypex performs the risk analysis by the following methods to prevent money laundering and financing of terrorism since it adopts a risk-based approach in monitoring its customers' financial activities, and it can monitor the related customers within the framework of the information obtained as a result of risk analysis.

Customers and transactions in the high risk group are as follows:

If the total amount of a single crypto currency transaction or multiple related transactions is equal to or more than 500,000 TL;

If the total amount of a single crypto currency exchange transaction or multiple related transactions is equal to or more than 500,000 TL;

In cases requiring suspicious transaction reporting within the framework of the current legislation;

If there is any doubt about the accuracy and adequacy of the credentials previously obtained;

If there are complex transactions with the potential to hide third party beneficiaries;

In cases where money sources cannot be easily verified;

Unusual transactions with any economic or visible legitimate purpose;

Transaction Monitoring

Monitoring customers' transactions and analysing the data obtained is also an important tool for risk assessment and detection of suspicious transactions. If there is a doubt about money laundering, Icrypex has the right to monitor all transactions (Customers and transactions in the high-risk group, Complex and unusual transactions, transactions with high-risk countries, customer-related information and documents, written and mandatory information required to be kept for crypto currency trading and transfer, whether a transaction made by a customer is appropriate for the information related to that transaction, etc.) and to:

Report suspicious transactions to the relevant law enforcement agencies;

Request the customer to provide additional information and documents;

Suspend or close the customer account;

The above list is not a comprehensive list; AML Policy Compliance Officer monitors customers' transactions daily, report customers and determines whether they are considered as suspicious.

Icrypex shall establish its own procedures to determine anti-money laundering standards and compliance with its Know Your Customer (KYC) policy.

Icrypex customers complete a verification procedure. Icrypex reserves the right to collect the credentials of its customers for the purposes of AML policy. This information is processed and stored securely in accordance with the Icrypex Privacy Policy.

Icrypex may request a second Customer ID document: (A bank receipt or electricity/water bill that contains the Customer's full name and actual address, not longer than 3 months)

Icrypex reserves the right to request additional information about Customers identified as dangerous or suspicious after confirming the accuracy of the documents and information submitted by customers.

If the Customer's identity information has been changed or its activities are found suspicious, Icrypex reserves the right to request updated documents from the Customer even if it has been verified in the past.

Reporting

Within the framework of the services provided by Icrypex, in cases of suspicion about money laundering and financing of terrorism, the Presidency of the Financial Crimes Investigation Board in accordance with the applicable legislation, regardless of the amount of transactions determined as a suspicious as a result of necessary investigations. Real persons who carry out the suspicious transaction and their legal representatives, managers and personnel who do not comply with the obligation to report the suspicious transaction shall be responsible for any legal, administrative and criminal sanctions.

Implementing a record management system for recording and retrieving documents, files, forms and daily session entries and exits;

Updating risk assessments regularly;

Training, Updating and Internal Audit

Icrypex fulfils personnel policy and procedures in accordance with the applicable legislation, and all obligations within the scope of training. In this context, it provides much training to its personnel, especially the Anti-Money Laundering Procedure, and ensures that this information is kept up to date.

Icrypex periodically audits whether activities regarding “Law on Money Laundering and Terrorism Financing”, regulations and communiqués are in compliance with the applicable legislation, Company policies and procedures.

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